Tax

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Can GILTI and the GloBE be harmonized in a Biden administration?
mnetax.com Mar 4, 2021
US Tax Court decision in Coca-Cola is at odds with economic principles
mnetax.com Mar 3, 2021
The US Tax Court accepted the IRS foreign affiliate “contract manufacturing” theory in the Coca-Cola v. Commissioner decision, issued Nov. 18, 2020. As Cambridge doyen economist Joan Robinson (1903-1983) used to say, “she who is convinced against...
Zambia introduces country-by-country reporting
mnetax.com Mar 3, 2021
The new regulations, published as Statutory Instrument (SI) No. 117 of 2020, are consistent with OECD guidelines on appropriate use. They provide that Zambia’s Commissioner-General will use the country-by-country report for high-level assessment of...
EU to negotiate public country-by-country reporting
mnetax.com Mar 3, 2021
EU public country-by-country reporting: final call
mnetax.com Mar 2, 2021
On 25 February, an informal meeting of internal market and industry ministers showed agreement amoung EU nations on public country-by-country reporting. The proposal, amending Directive n. 2013/34/EU, concerning the disclosure of income tax...
Jose E. Murillo named US Deputy Assistant Secretary for International Tax Affairs
mnetax.com Mar 2, 2021
First Look: India Supreme Court settles long-running dispute over taxation of software payments
mnetax.com Mar 2, 2021
India’s Supreme Court today ruled that software payments made by Indian end-users or distributors and resellers to overseas software suppliers are payments for sales, not royalties, and are therefore not subject to withholding tax under applicable...
Taiwan to impose new taxes on ecommerce
mnetax.com Feb 26, 2021
Offshore e-commerce suppliers that sell cross-border electronic services to individuals in the Republic of China (Taiwan) and have annual sales of more than NT $480,000 (US $17,224) must apply for tax registration in the R.O.C., according to a new...
Webinar: European holding companies investing in Germany in the light of new anti-treaty/directive-shopping rules
taxand.com Feb 25, 2021
Germany’s current applicable anti-treaty shopping provision has long been controversial. According to the provision, a foreign (holding) company is only entitled to WHT relief under a DTC or PSD if certain very specific substance requirements are...
EU court rejects Swedish rules limiting deductions for cross-border interest payments
mnetax.com Feb 24, 2021
In a ruling released January 20, the European Court of Justice found the Swedish rules on interest deduction limitations in breach of the EU law and freedom of establishment. The ruling concerned a Swedish company that had been denied a deduction...
Latest updates to EU list of non-cooperative jurisdictions
mnetax.com Feb 24, 2021
As of 22 February, the EU list of non-cooperative jurisdictions for tax purposes encompasses twelve countries: American Samoa, Anguilla, Fiji, Guam, Palau, Panama, Samoa, Trinidad and Tobago, US Virgin Islands, Vanuatu, Seychelles, and the newest...
Spain to scrutinize taxpayers’ transfer pricing positions in 2021
mnetax.com Feb 24, 2021
As in previous years, transfer pricing remains a key area of focus. The plan states that the government will direct tax enforcement efforts on the effective application of anti-avoidance measures, permanent establishments, and tax-haven...
Countries agree to new rules for private tax ruling transparency
mnetax.com Feb 22, 2021
An OECD-led coalition of 139 countries working together on cross-border tax issues known as the “Inclusive Framework on BEPS” has agreed to a new method for assessing whether countries meet global minimum standards for private tax ruling...
Trade groups sue over Maryland’s controversial tax on digital advertising
mnetax.com Feb 22, 2021
Four organizations have joined in a lawsuit challenging a new Maryland state law levying a tax on digital ad revenue – the latest twist in an ongoing dispute with international implications. The act aims to collect an estimated USD 250 million from...
Feedback sought on UN model tax treaty provision clarifying taxation of software payments
mnetax.com Feb 17, 2021
Is the description of “software” in paragraph 12.1 of the Commentary on Article 12 of the OECD Model (extracted in paragraph 12 of the proposed UN Commentary) (a) consistent with current business practice and (b) appropriate for use as a definition...
South Africa prevails with a TNMM analysis in transfer pricing dispute, but should it have?
mnetax.com Feb 17, 2021
A South African court, on December 3, 2020, allowed the South African Revenue Service (SARS) to prevail with a transactional net margin method (TNMM) analysis even though the taxpayer argued that its intercompany pricing was consistent with market...
EU Code of Conduct Group’s taxation work program released
mnetax.com Feb 17, 2021
On 9 February, the Council of the European Union released the Code of Conduct Group’s new work plan under the Portuguese Presidency. The EU Code of Conduct Group monitors jurisdictions within the European Union to determine if they cooperate from a...
Is the EU (unintentionally) undermining ongoing OECD work on digital taxation?
mnetax.com Feb 17, 2021
On 14 January, the European Commission published a so-called inception impact assessment and requested feedback on the design of an EU digital levy. According to the Commission, the EU digital levy will be targeted to address the EU’s need for a...
OECD publishes assessment of cross-border tax dispute resolution in 13 more countries
mnetax.com Feb 17, 2021
The OECD on February 1 published assessments of the cross-border tax dispute resolution processes in Aruba, Bahrain, Barbados, Gibraltar, Greenland, Kazakhstan, Oman, Qatar, Saint Kitts and Nevis, Thailand, Trinidad and Tobago, United Arab...
Qatar’s new transfer pricing documentation rules
mnetax.com Feb 10, 2021
Qatar published new transfer pricing regulations applicable from 1 January 2020, with the first returns due on 30 April for both resident companies in Qatar and permanent establishments of non-residents. This General Tax Authority transfer pricing...
Switzerland aims to make tax system more competative
mnetax.com Feb 8, 2021
Switzerland’s Federal Department of Finance is developing new tax rules designed to improve Switzerland’s attractiveness as a business location, Switzerland’s Federal Council announced February 4. The tax proposals will be based on a report...
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